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California Earthquake Authority, 25 v. Metropolitan West Securities

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA -- SACRAMENTO DIVISION


July 5, 2012

CALIFORNIA EARTHQUAKE AUTHORITY, 25, PLAINTIFF,
v.
METROPOLITAN WEST SECURITIES, LLC; WACHOVIA BANK, N.A.; AND DOES 1 THROUGH
DEFENDANTS.

The opinion of the court was delivered by: The Honorable Gregory G. Hollows United States Magistrate Judge

M ICHAEL J. S TRUMWASSER (SBN 58413) F REDRIC D. W OOCHER (SBN 96689) P ATRICIA T. P EI (SBN 274957) STRUMWASSER & WOOCHER LLP 10940 Wilshire Boulevard, Suite 2000 Los Angeles, California 90024 Tel.: (310) 576-1233 Fax: (310) 319-0156 E-mail: mstrumwasser@strumwooch.com fwoocher@strumwooch.com ppei@strumwooch.com Attorneys for Plaintiff California Earthquake Authority David C. Powell (SBN 129781) Email: dpowell@reedsmith.com Jesse L. Miller (SBN 183229) Email: jessemiller@reedsmith.com Christopher C. Foster (SBN 253839) Email: CFoster@reedsmith.com REED SMITH LLP 101 Second Street, Suite 1800 San Francisco, CA 94105-3659 Telephone: 415 543 8700 Facsimile: 415 391 8269 Attorneys for Defendants Metropolitan West Securities, LLC and Wells Fargo Bank, N.A., successor by merger to Wachovia Bank, N.A.

STIPULATION AND ORDER ON PARTIES' LIMITED PROTECTIVE ORDER AND PROTOCOL

Date action removed: February 4, 2010

Trial date: October 7, 2013

WHEREAS, Plaintiff California Earthquake Authority ("CEA") and Defendants Metropolitan West Securities LLC ("MetWest") and Wells Fargo Bank, N.A., successor by merger to Wachovia Bank, N.A. (collectively, "Defendants") have been meeting and conferring in good faith to reach a protocol governing the discovery issues remaining in this case;

WHEREAS, the parties submitted a stipulation on June 29, 2012 that was signed by this Court on July 3, 2012, which left the issue of the protocol and protective order to govern the production of data from the most recent MetWest GroupWise backup tape to the CEA open subject to further negotiations ("Backup Tape Protocol and Protective Order");

WHEREAS, the parties' agreement contemplated that the parties would continue to meet and confer in good faith regarding the Backup Tape Protocol and Protective Order, and that the parties would be able to reach a final agreement on the Backup Tape Protocol and Protective Order by July 3, 2012;

WHEREAS, the parties have continued to meet and confer in good faith on the Backup Tape Protocol and Protective Order;

WHEREAS, the parties have determined that they need to obtain additional technical information regarding the restoration of the MetWest GroupWise backup tape before they can reach a final agreement on the Backup Tape Protocol and Protective Order;

WHEREAS, the necessary technical information regarding the restoration of the MetWest GroupWise backup tape will not be available to the parties for a minimum of two weeks;

NOW, THEREFORE, IT IS HEREBY STIPULATED by and among Plaintiff California Earthquake Authority and Defendants Metropolitan West Securities, LLC and Wachovia Bank, N.A., through the undersigned counsel, that the parties be permitted an additional two weeks within which to reach an agreement on the limited discovery protocol to govern the production of the most recent MetWest GroupWise backup tape. The parties shall file the Backup Tape Protocol and Protective Order on or before Tuesday, July 17, 2012.

IT IS SO STIPULATED:

IT IS SO ORDERED:

Gregory G. Hollows

20120705

© 1992-2012 VersusLaw Inc.



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